The Competition and Markets Authority (CMA) said on Thursday it has begun an inquiry into Ryanair's practice of charging parents for seat reservations that ensure they sit next to their children on flights.
Under Ryanair's terms and conditions, at least one adult must sit with children aged 2-11 in what the airline describes as a "mandatory family seat." Parents and guardians are required to pay a seat reservation fee to secure a seat adjacent to their child, while other travellers may choose whether to reserve seats.
The charge applies to both outbound and return legs of a journey and is typically around A38 each way. CMA evidence indicates this seating policy is implemented on most of Ryanair's UK routes.
The regulator said it will investigate whether Ryanair's seat-reservation requirement effectively makes parents pay for the airline to discharge child safety or disability-related duties that arise under aviation rules, and whether that approach complies with consumer law.
Legal focus
The probe centers on whether the contract term that creates the mandatory family seat is "unfair" under consumer law. The CMA outlined that contract terms are considered unfair when they place consumers at a significant disadvantage by disproportionately allocating rights and responsibilities in favour of the business. In such instances, unfair terms are not legally binding on customers and the CMA has the power to take enforcement action to prevent their use.
As part of the review, the CMA will also examine how Ryanair presents the charge during the booking process. The inquiry will look at whether the mandatory family seat fee is added progressively - sometimes described as "dripped" into the consumer experience - and whether customers are shown the total price they will pay at the point of purchase. Consumer law requires that businesses display a total price that includes all unavoidable charges, rather than introducing compulsory extras separately or later in the booking flow.
The CMA noted that Ryanair is the only major carrier operating out of the UK that imposes this particular charge. By contrast, other airlines either seat children with a parent or guardian without insisting on a paid adult reservation, or they allocate seats together automatically at booking at no extra cost.
"Lots of families save up to afford a summer holiday and we know that extra charges can quickly bump up the price," said Hayley Fletcher, Senior Director of Consumer Protection. "Our investigation will consider Ryanair's approach to family seat reservations and how the cost is presented to consumers to determine whether they comply with consumer law."
The CMA emphasised that it is at the start of its investigation and has reached no conclusions about whether Ryanair has broken the law. The regulator expects to provide an update on the review within six months.
Context and presentation
Ryanair's own website refers to "Free reserved seats for kids under 12," but the company requires parents and guardians to pay a booking fee to access these seats. The CMA's inquiries will therefore scrutinize both the substance of the policy - whether parents are being charged for obligations that should rest with the airline - and the transparency of how that charge is communicated during booking.
The investigation may have implications for families who budget for seasonal travel and for the broader airline sector's approach to ancillary charges and on-board seating policies. The CMA's powers include ordering businesses to stop using unfair contract terms should it find they are in breach of consumer law.